Sanabria v. Brackett

When Ricky Sanabria, Jr. told a jail officer that he feared an attack by his increasingly aggressive cellmate, the officer moved him—but less than two hours later, the officer locked Mr. Sanabria back in with the cellmate. The very next day, the furious cellmate bit off Mr. Sanabria’s ear. After Mr. Sanabria sued, the district court told the jury to evaluate his claim under an improperly high legal standard. Co-counseling with Patrick Gallagher at Jacobs & Crumplar P.A., the MacArthur Justice Center is fighting to ensure that Mr. Sanabria and other pretrial detainees can get compensated for their injuries under the right standard. 

Mr. Sanabria’s case presents an important legal issue for people who are detained pending trial and who suffer harm because of jail officers’ failure to address obvious safety risks. The issue centers on the different legal frameworks for claims of unconstitutional conditions of confinement by (1) people already convicted of crimes, and (2) people who are detained pending trial, when they are presumed innocent. 

People convicted of crimes can lawfully be punished, and the Eighth Amendment protects them against punishments that are “cruel and unusual.” In contrast, people who are detained before trial cannot be punished at all, as they haven’t been found guilty of anything. Relying on this crucial distinction, the Supreme Court held in a 2015 case called Kingsley v. Hendrickson, 576 U.S. 389, that people detained before trial can show their rights were violated in detention based only on objective evidence—that is, evidence showing what a reasonable officer would have understood. In contrast, a prison official must have a “sufficiently culpable state of mind” to violate the Eighth Amendment. As a result, people who are incarcerated post-conviction must introduce evidence regarding prison officials’ own subjective understandings. 

The distinction made all the difference for Mr. Sanabria, who was detained pending trial in Delaware in 2021. For twenty-two hours a day, Mr. Sanabria was locked in a cell with another man, Kiyohn Carroll, who was bigger and stronger than him, and who was engaged in an escalating pattern of threatening behavior against him. Mr. Sanabria knew he wasn’t safe, so he told a housing officer that he feared an attack. The officer assured Mr. Sanabria that he’d help. The officer transferred Mr. Sanabria to a new, safer cell—for just 101 minutes, before he and a jail investigator opted to move Mr. Sanabria back into his old cell with Carroll. Carroll, furious, inferred that Mr. Sanabria had tried to leave him. And the very next day, just as Mr. Sanabria had feared, Carroll attacked. In the ensuing struggle, Carroll tore out Mr. Sanabria’s hair and bit off a chunk of his ear. 

Mr. Sanabria, represented by Jacobs & Crumplar P.A., sued the two officers for being deliberately indifferent to the serious risk Carroll posed. His claim against the housing officer proceeded to a trial before a jury. Mr. Sanabria presented ample evidence that the officer should have known of the risk. But even though Mr. Sanabria was a pretrial detainee, the district court told the jury to apply the stricter, subjective Eighth Amendment standard to his claim. Over Mr. Sanabria’s objections, the court instructed jurors that they could not rule for Mr. Sanabria if the housing officer didn’t subjectively believe Mr. Sanabria to be at risk, no matter how obvious the risk was. With its hands tied, the jury entered a verdict for the officer. 

The MacArthur Justice Center, alongside co-counsel Patrick Gallagher, represents Mr. Sanabria on appeal to the U.S. Court of Appeals for the Third Circuit. Mr. Sanabria’s appeal seeks to ensure that courts apply the proper standard—not an artificially more demanding one—for pretrial detainees’ claims that jail officials were deliberately indifferent to serious safety or medical risks.